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Privacy Policy

Preamble

This Privacy Policy constitutes an integral part of the General Conditions https://cokincokine.tv/cgv, the definitions used in these are also used in this Privacy Policy.

This Privacy Policy is aimed at informing the Members on the way in which their Personal Data is collected via the Platform, how these are processed by the Data Processor and finally the rights of the Members in regards to this Processing as defined hereafter..

Definitions

The following terms, whether used in the singular or plural in this Privacy Policy are defined as follows:

Archiving

Refers to the movement of Personal Data which still presents an administrative interest to the Data Processor, (for example in a contentious case and/or legal obligation case) into a distinct database which is logistically or physically separate, and for which, in either case, access is limited. This archiving is an intermediary step before the deletion of the Personal Data in question, or its anonymization.

Privacy Policy

Refers to this confidentiality policy and the protection of Personal Data of Members implemented by the Data Processor which constitutes an integral part of the GTSU.

Refers to data which is personal to the Member, within the meaning of the Regulation of Personal Data, collected and processed by the Data Processor in the framework of the creation and management of one’s personal Profile and the use of Services.

Regulations on personal data

dRefers to Law n°78-17 of the 6th of January 1978 regarding data processing, files and civil liberties and modified on the 7th of October 2016, as well as all regulations that would come to be applied to personal data, in particular in the application of the Community Regulation of the 27th of April 2016 published in the Official Journal of the European Union on the 4th of May 2016 in regards to the protection of individuals with regards to the processing of personal data and the free movement of this data.

Refers to the hardware (computer, tablet, smartphone, phone, etc.) used by the Member and/or the web user to consult or view the Platform and/or any other digital media edited by a third party.

Processing

Refers to, within the meaning of the Regulation on Personal Data, any action or set of actions, whether or not they are performed with the help of automated processes, applied to Personal Data, such as collection, registration, organization, structuring, preservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other way of making it available, alignment or interconnectivity, limitation, erasure or destruction.

The legal basis of the Processing

General regulations for the protection of data.

Purposes of Processing

The Personal Data of the Member is necessary to allow them access to the Services, the use of these services and their improvement, and to allow the Data Processor to:

carry out actions relating to their commercial relationship with the Member, i.e. concerning invoices, accounting, monitoring the "customer relationship" with a Member, such as conducting satisfaction surveys, management of complaints, use of the Platform and more generally Services, etc. ;

select Members to carry out studies, surveys and product tests, as well as loyalty, prospecting and promoting activities;

personalise their communication for the Members, in particular via email, in accordance with their noted preferences, from their use of the Services;

carry out activities relating to prospecting, in other words the management of technical prospecting activities (which notably includes technical activities such as standardization, enhancement and deduplication);

carrying out commercial soliciting activities;

the development of commercial statistics; analyses and tools in marketing (notably classification, score, etc.)

the organisation of contests, lotteries or all promotional activities, excluding online gambling subject to the approval of the Regulatory Authority for Online Games;

management of applications for the exercising of rights;

management of debts and litigation;

management of Members' comments on the Platform and/or on the web pages edited by the Data Processors, such as social network pages;

the fight against fraud.

The storage of personal data

All precautions have been taken to store the Personal Data of Members in a secure environment and to prevent them from being altered, damaged or for unauthorised third parties to have access to them. The information transmitted by the Member will never be transmitted to a third party with a commercial aim, nor sold or exchanged.

The collection of Personal Data on the Platform

The Data Processor collects, during the creation of an Account, and as and when this is complete, the following Personal Data, which the Member submits or communicates while browsing, and which is kept for a duration of three (3) years, in an active database, from the last connection of the Member to the Platform :

Email address

Identifier used on Platform

Payment ID

If applicable, the reason(s) for the exclusion (all of the elements which demonstrate the actions dating less than one month and which justify the exclusion)

Connection data (date, time, IP address, pages visited) of the Member whilst browsing on the Platform

The Personal Data above is also kept in the Intermediary Archive for a duration of two (2) extra years, in accordance with the common limitation period.

Payment Tickets

Amount of the transactions carried out as well as the date and time of these transactions

The Personal Data above are also kept in the Intermediary Archive for a duration of ten (10) extra years, in accordance with the fiscal and accounting obligations of the Data Processor.

Only the Personal Data defined on the Platform as obligatory is indispensable to have an Account.

Recipients or recipient categories if they exist

Country in which data recipient is established

Nature of transmitted data

Purpose of proposed transfer

Data recipient categories

Level of protection offered by the country or exception provided for by the Regulations on Personal Data

MALTA

Payment

Payment

Payment provider

Subject to the European GDPR regulation

EU

Payment

Payment

Payment provider

Subject to the European GDPR regulation

Ireland

Tracking

Analysis of traffic

Analysis of traffic

Subject to the European GDPR regulation

Switzerland

Tracking

Analysis of traffic

Analysis of traffic

Subject to the Swiss regulation

USA

Personal Data

Client support

Customer relationship management software

Security of transactions on the Internet

In accordance with the General Conditions, the Platform uses the technology of an external partner, to secure the bank transactions of the Members.

Thus, when paying on the Platform, the bank details of the Member are transmitted encrypted to an external partner, without the Data Processor being able to read them.

The Data Processor does not collect the full number of the Member's bank card, nor the cryptogram.

The rights of Members

The member can, at any time:

Oppose and/or cancel and/or limit and/or withdraw their consent to all or part of the Processing of their Personal Data made within the framework of the Services provided on the Platform for legitimate reasons;

Access all their Personal Data processed in the framework of the Services, including for portability purposes provided that this is specified

Correct and/or update their processed Personal Data in the framework of the Services!

get an audio reading of this privacy policy.

Additionally, the Member has the opportunity to define, with the Data Processor, the guidelines for the retention, erasure and communication of their Personal Data after their death, which may also be registered with "a third party whose digital trustworthiness is certified". These guidelines, or "digital will" of sorts, may designate a person to perform them; failing this, the next of kin of the Member will be appointed.

In the absence of any guidance, the next of kin may contact the Company in order to:

access data processing which allows for "the organization and settlement of the legacy of the deceased";

receive communications of "digital assets" or "data on family memories, communicable to next of kin";

proceed to closing their Account and oppose further processing of their Personal Data

In all circumstances, the Member can indicate, at any time, to the Data Processor that they do not wish, in the event of death, to have their Personal Data communicated to a third party

For the purpose of asserting their rights under the conditions set out above, the Member must prove their identity by mentioning their surname, forename, e-mail address and accompanying their application for the copy with their identity card.

The advertising identifier linked to the operating system of their Device;

The IP address of their Device;

The geolocation data of their Device;

Their language preferences.

Information on their browsing and their behaviour on the Platform:

the statistics on their views of different pages on the Platform;

the complete URL routing to, via and from the Platform;

Information concerning the Member (age or age group, sex, socio-professional category declared and/or inferred, interests inferred, etc.) related to their activity on the Internet and communicated by third parties (advertisers, advertising agencies, etc).

Cookies of the Data Processor

Service and type of cookie

Role of cookie and data collected

Duration

Site settings

Last used settings for sounds, notifications , visualisation

12 months

Visitor identification

Last used visitor id

12 months

Site session ID

ID for session tracking

session

Campaign tracking

Identifiers to track marketing campaigns

12 months

Third party cookies

Service and type of cookie

Role of cookie and data collected

Duration

Google Analytics

Campaign tracking

24 months

Opposition to cookies

The web user and/or Member is informed, from their first visit, that they can reject the storing of cookies which are ancillary to the functioning of the Platform, which they can do by configuring their Internet browser to do this or by exercising their choices on this page (see below).

When the web user and/or Member browses on the Platform, information may be stored, or read, in their Device, according to their choices.

Do you accept the submission and reading of cookies so that we can analyse your interests to customize the website during your visit?

Yes

No

Do you accept the submission and reading of cookies so that we can analyse your browsing and allow us to measure the audience on our Site:

Yes

No

Do you accept the submission and reading of cookies so that we and our partners can analyse your interests to offer you personalised advertisements?

Yes

No

Do you accept the submission and/or reading of cookies to allow you to share the contents of our site with other people or to make known to these other people your browsing or your opinions (Facebook "Like" buttons for example):

Yes

No

You can inform us of your choice by sending this questionnaire back to data@dnxnetwork.lu.

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